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The Credentialing Brief · Issue 2, November 2026
Every revocation retroactive: the 2027 enrollment proposal and what to change now
Short answer: CMS-1844-P would make every Medicare revocation reach back to the day non-compliance began; the 30- and 90-day reporting deadlines become payment dates; the revalidation clock is yours to track. Proposed, not final.
CMS-1844-P · 91 FR 41216
42 CFR 424.516 · 30 / 90 days
42 CFR 424.541 · stay, 60 days
Not final as of this issue
Edition
Issue 2 · Nov 2026
Focus
Retroactive revocation
Audience
Credentialing leads
Framework
CMS-1844-P
Effective date
Proposed, not final
Length
5 min read
CMS proposes to make every revocation retroactive
CMS-1844-P, 91 FR 41216, July 6, 2026, reaches every provider and supplier type; comments closed August 31 [1]. Today a revocation starts 30 days after notice unless on the 424.535(g) list; the fact sheet: all grounds retroactive [2]. Sections: CY 2027 proposals insight.
- 1Day 1A licence lapses or a change goes unreported
- 2Day 45CMS learns of it and mails a revocation notice
- 3Today: day 75Prospective grounds take effect 30 days after mailing
- 4Proposed: day 1Effective date is day 1; everything paid since is at risk [1]
Paid today
Days 1 to 75 stay paid
At risk, proposed
Days 1 to 75 become overpayments
Current ruleProposed rule
The reporting deadlines that would carry money
A late change report would be revoked back to the day after it was due, for every kind of change [1]; today only ownership, adverse actions and locations. The deadlines do not move [4].
| Event [4] | Deadline today | Proposed revocation effective date [1] |
|---|---|---|
| Change of ownership | 30 days | Day after the report was due |
| Adverse legal action | 30 days | Day after the report was due |
| Practice location added, changed or closed | 30 days | Day after the report was due |
| Managing employee, officer, billing agent, bank, address, anything else | 90 days | Day after the report was due new under the proposal |
Days of paid claims at risk, example above
Illustrative days from Story 1 [1].
Todayday 75
0 days0%
Proposedday 1
75 days100%
30-day report missedproposed
day 3141%
90-day report missedproposed
day 91past the window
0255075 days
Current ruleProposed ruleReporting deadlines, 424.516
Six more changes, all proposed
| Proposal [1] [2] | Section |
|---|---|
| Enrolling under another party’s identity | New 424.530(a)(21) |
| Same suite as a revoked or denied provider | New 424.530(a)(19) |
| Hospice directors serving multiple hospices or too distant | New 424.530(a)(20) |
| Reapplication bar up to 10 years after any denial reason | 424.530(f) |
| Majority-ownership change inside 36 months at HHAs, hospices, DMEPOS | New 424.530(a)(22), 424.535(a)(25) |
| Revocation grounds extended to actions involving owners or managing employees | Described in the CMS fact sheet |
The revalidation clock CMS says is yours to track
No extensions, no exemptions; late means a hold or deactivation, and nothing is paid while deactivated [3].
Our revalidation calendar turns the window into a monthly routine.
New this month
Service tiers
Credentialing
- Credentialing page, three tiers
Issue 1
Archive
Takeaway
Check when every change from the last 12 months reached the MAC against the 424.516 deadlines. Anything late is the list the proposal would price.
Three steps this week
Export 12 months of changesHires, departures, locations, ownership, officers, bank or billing agent.
Compute days from event to reportFrom the PECOS or CMS-855 submission date.
File anything still unreported nowAdd a 30- and 90-day report step to onboarding, offboarding and move checklists; a monthly KPI in the operating model, run for clients by our credentialing team.
Frequently asked questions
Is the retroactive revocation rule in force?
No. It is in CMS-1844-P, the CY 2027 Home Health PPS proposed rule published July 6, 2026; comments closed August 31, 2026. Nothing changes until CMS publishes a final rule.
Does the proposal only apply to home health agencies?
No. CMS states the section V.C enrollment provisions apply to all Medicare provider and supplier types except where a provision says otherwise.
Which enrollment changes must be reported within 30 days?
A change of ownership, any adverse legal action, and a change, addition or deletion of a practice location, under 42 CFR 424.516. All other changes have 90 days.
- Federal Register, 91 FR 41216 (July 6, 2026): CY 2027 Home Health PPS proposed rule, CMS-1844-P, section V.C Provider Enrollment (proposed, comments closed August 31, 2026)
- CMS fact sheet: Calendar Year (CY) 2027 Home Health Prospective Payment System Proposed Rule (CMS-1844-P), July 1, 2026
- CMS, Medicare Enrollment: Revalidations (cycle, due-date posting, notices, consequences)
- 42 CFR 424.516, Additional provider and supplier requirements for enrolling and maintaining active enrollment status (reporting deadlines)
- 42 CFR 424.541, Stay of enrollment
- CMS, Medicare Provider Enrollment Compliance Conference, March 18 to 19, 2026: provider resources (revalidation list, stay of enrollment education, EUS)
Checked October 25, 2026. Rules change; confirm against the source before relying on them. CMS-1844-P is a proposed rule and nothing in it is final until CMS publishes the final rule.
White paperCredentialing revalidation operating model 2027
InsightCY2027 provider enrollment proposals
BlogAvoid a stay of enrollment
ArchiveThe Credentialing Brief
NewsletterPECOS revalidation timeline
ServiceCredentialing and payer enrollment
ServiceMedical credentialing services
GuideEvaluating credentialing vendors
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